click to enlarge

How big will the channel deepening footprint be?

Can we be sure it will not add to the present problems

in the fish and penguin population caused by drought?

What will happen to all the other sea birds?

How many buried toxins will be released?

Submission to Planning Panels Victoria, Channel Deepening Project SEES.

Potential Impacts of Channel Deepening in Port Phillip Bay

Introduction

Earthcare St Kilda Inc. is a community environment group currently comprised of 64 members centred on the City of Port Phillip, with a concern for conservation and environmental issues in the local and wider area. Although the main focus of Earthcare is the research and monitoring of the Little Penguin colony on St Kilda Breakwater (study now in its 20^th year), the group is also involved with other projects including rakali (native water rat) population study, monitoring of water quality, and the regeneration of natural heritage areas to increase the extent of indigenous vegetation and biodiversity.

It is a policy of the group not to be anti-development, but rather support sustainable development based on sound science and with minimum adverse impacts on the environment or the community. Earthcare takes an active interest in proposed development in the local area, especially if it is located along the foreshore, in parklands or Port Phillip Bay, and will get involved or take action where it considers it necessary.

Penguin research commenced in 1986 when the then City of St Kilda Council asked Professor Mike Cullen (Monash University Ecology & Evolutionary Biology Department) to undertake research and assess the importance of the breakwater’s Little Penguin colony. With St Kilda ranger, Neil Blake, Professor Cullen commenced an ongoing voluntary study of the colony, which is continuing to the present day under the management of Zoe Hogg; St Kilda Penguin Study Group incorporated in Earthcare St Kilda.

Earthcare St Kilda is a member of the St Kilda Breakwater Wildlife Management Co-operative Area Advisory Group, comprised of representatives from the St Kilda Yacht Squadron, Parks Victoria, City of Port Phillip and St Kilda Ecocentre. The purpose of the group is to oversee and make decisions on a range of issues relating to the management of St Kilda Harbour.

Earthcare St Kilda’s Little Penguin study group has hosted thousands of visitors over the years, including primary, secondary and tertiary students, and there are two Little Penguin tour operators at St Kilda. One of them Urban Penguins a company based at Docklands has written a letter of support for our submission (Appendix 1).

Earthcare St Kilda has deep concerns about the proposed Channel Deepening Project by the Port of Melbourne Corporation (PoMC), and has made a submission and presentation in the previous EES process (Submission No. 161).

General observations on the SEES and the SEES process

We are surprised and disappointed that the Victorian Government has appointed an entirely new independent panel completely excluding members of the previous panel. Compared to the original EES Panel the new members do not appear to have the expertise or experience to properly review and make decisions on the complex issues. This leads us to the opinion that the Victorian Government does not wish to undertake a thorough review, but rather rush the process in order to achieve a positive outcome for Channel Deepening to go ahead.

While we acknowledge that there has been some formal engagement with the community by the PoMC and its consultants, we found the level of public involvement to be minimal for such a large, complex and important project. Six weeks is simply too little time available for the public to thoroughly review and make a submission in response to complex issues contained in the new 15,000 page environmental report. Even worse the time limit set at four weeks for the SEES hearing process to deal with such a range of complex issues is contemptible. This clearly indicates that the Victorian Government and PoMC have a limited genuine regard for the environmental health of Port Phillip Bay.

We note, as we did with the previous EES process, there has been a clear decision by the Victorian Government not to examine alternatives, such as use of other ports and/or rail from other states.

No effort has been made to prepare an estimate of possible economic losses, which could potentially be very high and directly affect businesses that depend on and communities living beside the Bay, if the condition of the Bay deteriorates as a direct result of channel deepening. The economic benefits are difficult to accept for a project with a current estimated cost of over $750 million and still rising, and which do not cover additional costs of major changes to land based infrastructure such as relocation of the Footscray Market, as well as potential losses caused by damage to the bay.

Earthcare’s concerns about potential impacts caused by proposed channel deepening to the bay

Sea level, tides, currents and waves

It is difficult for a group such as Earthcare to comment with authority about the SEES findings and the testimony of expert witnesses that there will be little impact from the Project on sea levels, waves, currents or tides. However, we do have concerns if the predictions in the SEES are wrong.

In particular we are sceptical about the modelling which predicts the extent of the dredging plumes beyond the site of dredging activities in the shipping channels, especially in the northern part of the bay where the particles are very fine. There is a very high risk that these fine sediments along with the toxins and heavy metals contained within will be resuspended and carried further every time there is a significant storm event.

Reduced nutrient processing capacity

We still believe, as we did with the previous EES, that there is a real risk to denitrification process in the bay. The 1996 CSIRO Port Phillip Bay Environmental Effects Study recommended that dredging in Port Phillip Bay be minimised in order to protect the vital denitrification function of the benthic organisms within the Bay sediments and water column. This is a major reason why scallop dredging in Port Phillip Bay ceased.

We urge that the precautionary principle be applied and this issue be given the most serious consideration, both in terms of whether the Project should go ahead at all and, if given the go ahead, what must be done and by whom, to monitor the dredging program to prevent loss of the nitrogen processing capacity of the Bay.

Increased risk of oil spills

Were an oil tanker to run aground at the Port Phillip Heads, the consequent oil-spill would be a monumental environmental, social and economic disaster. We believe that restrictive measures should be in place to prevent oil tankers with a draft in excess of 12 metres from being allowed to enter the Bay, even if the decision is made to deepen the channel at the entrance to the Bay.

Stability of Dredge Material Ground

It has been estimated that the effective life of the capping to be placed over sediments with toxic material will last for 30 years, before toxic materials, algal cysts and other dangerous substances will have the potential to re-enter the water column in the bay. No commitment is given to monitor the effectiveness of the capping or to place further capping material if leakage is detected.

It seems that this issue will be shrugged off by the proponent through short term planning, only to be left as a nasty legacy for future generations to deal with.

Dredging schedule for Yarra River and Hobsons Bay

If the decision is made by the Victorian Government that the Channel Deepening Project is to go ahead we are deeply concerned about the schedule for dredging the Yarra River (Mid-sized TSHD and Backhoe/Grab dredge) in Summer and autumn, and Williamstown Channel in late winter to spring (Mid-sized TSHD) and again in autumn (Backhoe/Grab dredge). Our major concerns are threefold; Firstly there is a high risk to human health from toxins, heavy metals and algal cysts from dredge plumes possibly reaching the northern bay shores at a time of peak recreational use in the summer, secondly this is at the time of spawning by Anchovy (Engraulis australis), which is from October to March peaking in January (Aquaculture and Fisheries SEES), and thirdly the St Kilda and Phillip Island penguins rely on Port Phillip Bay fish stocks to attain breeding condition in winter and early spring. Research undertaken by Earthcare has demonstrated that anchovy comprise over ninety percent of the diet of the St Kilda population of Little Penguins.

This concern about the schedule of dredging was raised by Earthcare in the previous EES process (Submission No. 161), for which we suggested almost no seasonal ‘window of opportunity’ exists, when the works would not cause some potential harm to the Little Penguin Colony at St Kilda Harbour and ecology in the northern area of the Bay. If dredging is to go ahead, a very narrow window of opportunity may exist in late autumn to early winter, when conditions in the Bay are relatively calm and penguins have completed moulting, but have not yet commenced breeding.

Potential impacts of the Channel Deepening Project on the St Kilda population of Little Penguins (Eudyptula minor)

The St Kilda population of little penguins is both locally and globally significant. Locally, the penguins are an iconic species, enjoyed by locals and tourists alike. The colony attracts numerous visitors and supports at least two tour operation businesses. The colony is supported by the City of Port Phillip sister city of Obu in Japan by annual grants and visitation. Penguins living at St Kilda are a unique example of how a wild population of animals can live successfully in very close proximity to an urban area, and offer many insights into urban ecology, all of which are as yet not fully investigated and understood.

Earthcare St Kilda has a number of concerns about the effect of the channel deepening project on the St Kilda population of little penguins. These concerns were outlined to the panel hearing on the channel deepening project after the release of the first environmental effects statement (Submission No. 161). We believe that the SEES commissioned by the Port of Melbourne Corporation has failed to accurately assess the impacts of the channel deepening project on little penguins, and they face both direct and indirect threats to their survival and breeding success from this project.

Since the first environmental effects statement, we have conducted our own research on the penguin population from St Kilda and found that spring and summer distribution patterns of penguins differ greatly from those reported in the SEES. Using state of the art remote satellite tracking devices, we found that penguins are in locations likely to be greatly effected by the channel deepening project. In addition, information from data loggers we used to study the diving patterns of penguins has revealed that they use the whole water column to search and hunt for food. This use of the entire water column, together with their pattern of distribution, will mean that the turbidity caused by channel deepening is likely to have a significant effect on this small population of Little Penguins.

In light of the above research, we wish to question several aspects of the SEES (in particular appendix 56) and the assessment of the impact of the CDP on Little Penguins as “minor”, based on a number of reasons, including but not limited to:

- The way in which the survey of Little Penguin distribution was conducted and the distribution maps which were used to assess the impact of the CDP on little penguins

- Assumptions made and use of the Population Viability Analysis model

- Calculation of the ‘consequences’ and ‘risk quotients’

- Assessment of the effects of the CDP on anchovy, a primary food source for Little Penguins in Port Phillip Bay and a complete disregard of penguins supplementary food (squid) and other fish species (including sandy sprat and garfish)

The level of detail about our objections to the channel deepening project in this submission is indicative of the limited time given to read and respond to the 15,000 page SEES. However, we are expressing interest in making a more detailed oral presentation on Earthcare’s concerns about the channel deepening project, the failings of the SEES and what we perceive to be the actual effects of the channel deepening project on Little Penguins, to the panel inquiry hearing for this project.

The following members of Earthcare St Kilda wish to make a presentation to the panel hearing:

Mr Andrew McCutcheon

Earthcare St Kilda Inc President

	Channel Deepening in Port Phillip Bay

	click to enlarge How big will the channel deepening footprint be? Can we be sure it will not add to the present problems in the fish and penguin population caused by drought? What will happen to all the other sea birds? How many buried toxins will be released? Submission to Planning Panels Victoria, Channel Deepening Project SEES. Potential Impacts of Channel Deepening in Port Phillip Bay Introduction Earthcare St Kilda Inc. is a community environment group currently comprised of 64 members centred on the City of Port Phillip, with a concern for conservation and environmental issues in the local and wider area. Although the main focus of Earthcare is the research and monitoring of the Little Penguin colony on St Kilda Breakwater (study now in its 20^th year), the group is also involved with other projects including rakali (native water rat) population study, monitoring of water quality, and the regeneration of natural heritage areas to increase the extent of indigenous vegetation and biodiversity. It is a policy of the group not to be anti-development, but rather support sustainable development based on sound science and with minimum adverse impacts on the environment or the community. Earthcare takes an active interest in proposed development in the local area, especially if it is located along the foreshore, in parklands or Port Phillip Bay, and will get involved or take action where it considers it necessary. Penguin research commenced in 1986 when the then City of St Kilda Council asked Professor Mike Cullen (Monash University Ecology & Evolutionary Biology Department) to undertake research and assess the importance of the breakwater’s Little Penguin colony. With St Kilda ranger, Neil Blake, Professor Cullen commenced an ongoing voluntary study of the colony, which is continuing to the present day under the management of Zoe Hogg; St Kilda Penguin Study Group incorporated in Earthcare St Kilda. Earthcare St Kilda is a member of the St Kilda Breakwater Wildlife Management Co-operative Area Advisory Group, comprised of representatives from the St Kilda Yacht Squadron, Parks Victoria, City of Port Phillip and St Kilda Ecocentre. The purpose of the group is to oversee and make decisions on a range of issues relating to the management of St Kilda Harbour. Earthcare St Kilda’s Little Penguin study group has hosted thousands of visitors over the years, including primary, secondary and tertiary students, and there are two Little Penguin tour operators at St Kilda. One of them Urban Penguins a company based at Docklands has written a letter of support for our submission (Appendix 1). Earthcare St Kilda has deep concerns about the proposed Channel Deepening Project by the Port of Melbourne Corporation (PoMC), and has made a submission and presentation in the previous EES process (Submission No. 161). General observations on the SEES and the SEES process We are surprised and disappointed that the Victorian Government has appointed an entirely new independent panel completely excluding members of the previous panel. Compared to the original EES Panel the new members do not appear to have the expertise or experience to properly review and make decisions on the complex issues. This leads us to the opinion that the Victorian Government does not wish to undertake a thorough review, but rather rush the process in order to achieve a positive outcome for Channel Deepening to go ahead. While we acknowledge that there has been some formal engagement with the community by the PoMC and its consultants, we found the level of public involvement to be minimal for such a large, complex and important project. Six weeks is simply too little time available for the public to thoroughly review and make a submission in response to complex issues contained in the new 15,000 page environmental report. Even worse the time limit set at four weeks for the SEES hearing process to deal with such a range of complex issues is contemptible. This clearly indicates that the Victorian Government and PoMC have a limited genuine regard for the environmental health of Port Phillip Bay. We note, as we did with the previous EES process, there has been a clear decision by the Victorian Government not to examine alternatives, such as use of other ports and/or rail from other states. No effort has been made to prepare an estimate of possible economic losses, which could potentially be very high and directly affect businesses that depend on and communities living beside the Bay, if the condition of the Bay deteriorates as a direct result of channel deepening. The economic benefits are difficult to accept for a project with a current estimated cost of over $750 million and still rising, and which do not cover additional costs of major changes to land based infrastructure such as relocation of the Footscray Market, as well as potential losses caused by damage to the bay. Earthcare’s concerns about potential impacts caused by proposed channel deepening to the bay Sea level, tides, currents and waves It is difficult for a group such as Earthcare to comment with authority about the SEES findings and the testimony of expert witnesses that there will be little impact from the Project on sea levels, waves, currents or tides. However, we do have concerns if the predictions in the SEES are wrong. In particular we are sceptical about the modelling which predicts the extent of the dredging plumes beyond the site of dredging activities in the shipping channels, especially in the northern part of the bay where the particles are very fine. There is a very high risk that these fine sediments along with the toxins and heavy metals contained within will be resuspended and carried further every time there is a significant storm event. Reduced nutrient processing capacity We still believe, as we did with the previous EES, that there is a real risk to denitrification process in the bay. The 1996 CSIRO Port Phillip Bay Environmental Effects Study recommended that dredging in Port Phillip Bay be minimised in order to protect the vital denitrification function of the benthic organisms within the Bay sediments and water column. This is a major reason why scallop dredging in Port Phillip Bay ceased. We urge that the precautionary principle be applied and this issue be given the most serious consideration, both in terms of whether the Project should go ahead at all and, if given the go ahead, what must be done and by whom, to monitor the dredging program to prevent loss of the nitrogen processing capacity of the Bay. Increased risk of oil spills Were an oil tanker to run aground at the Port Phillip Heads, the consequent oil-spill would be a monumental environmental, social and economic disaster. We believe that restrictive measures should be in place to prevent oil tankers with a draft in excess of 12 metres from being allowed to enter the Bay, even if the decision is made to deepen the channel at the entrance to the Bay. Stability of Dredge Material Ground It has been estimated that the effective life of the capping to be placed over sediments with toxic material will last for 30 years, before toxic materials, algal cysts and other dangerous substances will have the potential to re-enter the water column in the bay. No commitment is given to monitor the effectiveness of the capping or to place further capping material if leakage is detected. It seems that this issue will be shrugged off by the proponent through short term planning, only to be left as a nasty legacy for future generations to deal with. Dredging schedule for Yarra River and Hobsons Bay If the decision is made by the Victorian Government that the Channel Deepening Project is to go ahead we are deeply concerned about the schedule for dredging the Yarra River (Mid-sized TSHD and Backhoe/Grab dredge) in Summer and autumn, and Williamstown Channel in late winter to spring (Mid-sized TSHD) and again in autumn (Backhoe/Grab dredge). Our major concerns are threefold; Firstly there is a high risk to human health from toxins, heavy metals and algal cysts from dredge plumes possibly reaching the northern bay shores at a time of peak recreational use in the summer, secondly this is at the time of spawning by Anchovy (Engraulis australis), which is from October to March peaking in January (Aquaculture and Fisheries SEES), and thirdly the St Kilda and Phillip Island penguins rely on Port Phillip Bay fish stocks to attain breeding condition in winter and early spring. Research undertaken by Earthcare has demonstrated that anchovy comprise over ninety percent of the diet of the St Kilda population of Little Penguins. This concern about the schedule of dredging was raised by Earthcare in the previous EES process (Submission No. 161), for which we suggested almost no seasonal ‘window of opportunity’ exists, when the works would not cause some potential harm to the Little Penguin Colony at St Kilda Harbour and ecology in the northern area of the Bay. If dredging is to go ahead, a very narrow window of opportunity may exist in late autumn to early winter, when conditions in the Bay are relatively calm and penguins have completed moulting, but have not yet commenced breeding. *Potential impacts of the Channel Deepening Project on the St Kilda population of Little Penguins (Eudyptula minor)* The St Kilda population of little penguins is both locally and globally significant. Locally, the penguins are an iconic species, enjoyed by locals and tourists alike. The colony attracts numerous visitors and supports at least two tour operation businesses. The colony is supported by the City of Port Phillip sister city of Obu in Japan by annual grants and visitation. Penguins living at St Kilda are a unique example of how a wild population of animals can live successfully in very close proximity to an urban area, and offer many insights into urban ecology, all of which are as yet not fully investigated and understood. Earthcare St Kilda has a number of concerns about the effect of the channel deepening project on the St Kilda population of little penguins. These concerns were outlined to the panel hearing on the channel deepening project after the release of the first environmental effects statement (Submission No. 161). We believe that the SEES commissioned by the Port of Melbourne Corporation has failed to accurately assess the impacts of the channel deepening project on little penguins, and they face both direct and indirect threats to their survival and breeding success from this project. Since the first environmental effects statement, we have conducted our own research on the penguin population from St Kilda and found that spring and summer distribution patterns of penguins differ greatly from those reported in the SEES. Using state of the art remote satellite tracking devices, we found that penguins are in locations likely to be greatly effected by the channel deepening project. In addition, information from data loggers we used to study the diving patterns of penguins has revealed that they use the whole water column to search and hunt for food. This use of the entire water column, together with their pattern of distribution, will mean that the turbidity caused by channel deepening is likely to have a significant effect on this small population of Little Penguins. In light of the above research, we wish to question several aspects of the SEES (in particular appendix 56) and the assessment of the impact of the CDP on Little Penguins as “minor”, based on a number of reasons, including but not limited to: - The way in which the survey of Little Penguin distribution was conducted and the distribution maps which were used to assess the impact of the CDP on little penguins - Assumptions made and use of the Population Viability Analysis model - Calculation of the ‘consequences’ and ‘risk quotients’ - Assessment of the effects of the CDP on anchovy, a primary food source for Little Penguins in Port Phillip Bay and a complete disregard of penguins supplementary food (squid) and other fish species (including sandy sprat and garfish) The level of detail about our objections to the channel deepening project in this submission is indicative of the limited time given to read and respond to the 15,000 page SEES. However, we are expressing interest in making a more detailed oral presentation on Earthcare’s concerns about the channel deepening project, the failings of the SEES and what we perceive to be the actual effects of the channel deepening project on Little Penguins, to the panel inquiry hearing for this project. The following members of Earthcare St Kilda wish to make a presentation to the panel hearing: Mr Andrew McCutcheon Earthcare St Kilda Inc President